Sanctions & AML Policy

Last updated:

1. Overview

Red Cell Advisory is committed to full compliance with all applicable sanctions and anti-money laundering (AML) laws and regulations. This policy outlines our framework for preventing money laundering, terrorist financing, and sanctions violations.

2. Sanctions compliance

We comply with sanctions programs administered by:

  • United Nations Security Council
  • United States (OFAC)
  • European Union
  • United Kingdom (HM Treasury)
  • Other relevant jurisdictions

We do not engage in business with sanctioned individuals, entities, or countries, and we screen all clients and transactions against applicable sanctions lists.

3. Anti-Money Laundering program

Our AML program includes:

  • Written policies and procedures
  • Designated AML compliance officer
  • Ongoing employee training
  • Independent audit function
  • Customer due diligence procedures
  • Ongoing monitoring and reporting

4. Customer due diligence

We conduct appropriate due diligence on all clients, including:

  • Identity verification
  • Beneficial ownership identification
  • Risk assessment based on client profile
  • Enhanced due diligence for high-risk clients
  • Ongoing monitoring of client relationships

5. Screening and monitoring

We maintain robust screening and monitoring systems to detect suspicious activities and ensure compliance with sanctions requirements. This includes real-time screening against sanctions lists and ongoing transaction monitoring.

6. Record keeping

We maintain comprehensive records of all client due diligence, transactions, and compliance activities in accordance with applicable legal requirements. Records are retained for the required periods and made available to regulators upon request.

7. Suspicious activity reporting

We have procedures in place to identify, investigate, and report suspicious activities to relevant authorities as required by law. All employees are trained to recognize and report potential money laundering or sanctions violations.

8. Training and awareness

All employees receive regular training on AML and sanctions compliance appropriate to their roles. Training covers legal requirements, internal procedures, and red flag indicators.

9. Enforcement

Violations of this policy may result in disciplinary action, termination of business relationships, and reporting to relevant authorities. We cooperate fully with law enforcement and regulatory investigations.

10. Contact

For questions about sanctions and AML compliance, contact our compliance team at legal@redcelladvisory.com or:
Red Cell Advisory — a unit of Burakorn Partners Holding
30th Floor, Bhiraj Tower at EmQuartier, Sukhumvit Road, Khlong Tan Nuea, Watthana, Bangkok 10110